I have filed an
affidavit dated 28.09.2000. That may be treated as my examination in
chief. I further say that the affidavit is W1/1 (No.2164).

I am a Writer.
I have written several books and edited various magazines. I occasionally
write articles for Indian newspapers and magazines and for “The New York
Times”, etc, and have also written 7 books. I have lived since my birth in
Delhi. I have known Mr.I.K.Gujral for over 50 years, Air Chief Marshal
Arjun Singh since 30 years, and Lt. Gen. J.S.Aurora for the last 50 years.
The Sikh community in India accords me respect and Sikhs residing abroad
also consult me occasionally in matters of interest to the Sikhs. I have
written extensively on Sikh temporal and religious matters. My family was
involved in the building of New Delhi. I have been much involved in
humanitarian issues and matters of social and political concern.

I knew Ms.Indira
Gandhi and some other members of the family. Ms.Gandhi visited my house
when she was Prime Minister. On certain occasions I discussed with her
several matters of public importance. I also knew Giani Zail Singh, the
President of India.

I am the author
of a book entitled, “Of Dreams and Demons – An Indian Memoir”. The reason I
am mentioning this book is that in it I compared the situation in Delhi
after the assassination of Mahatma Gandhi, with the assassination of Ms.
Indira Gandhi, 36 years later. Before the news with regard to the
assassination of Mahatma Gandhi was broadcast on AIR, steps were taken to
maintain strict law and order with a view to avoiding bloodshed in the
streets of the capital in the wake of his assassination, in case it turned
out to be a killing by a person of different religious persuasion. The
Police and the Army were duly alerted. The broadcast of the news was
stalled for some time deliberately so as to make the necessary security
arrangements. Unfortunately, no such precautions were taken by any of the
authorities before broadcasting news of the assassination of Ms. Indira
Gandhi, to the best of my knowledge. Rather, on the television, I noticed
that almost every 15 minutes crowds were shown shouting the slogan “ KHOON
KA BADLA KHOON” obviously with the aim of instigating communal violence. I
may at this stage mention that what I have stated with regard to the
stalling of the news of Mahatma Gandhi’s that what I have stated with regard
to the stalling of the news of Mahatma Gandhi’s assassination was done at
the instance of the then Governor General of India, Lord Louis Mountabatten.
According to me the action taken by him showed more concern for human lives
than was shown by the Indian leadership in 1984, because the steps he took
to ensure the maintenance of peace and order were steps any law-abiding
leadership is expected to take under such circumstances.

My request to
Lt. Gen. J.S. Aurora (Retd.), Sardar Gurbachan Singh, Ex-Ambassador, Air
Chief Marshal Arjun Singh, and Brig, Sukhbir Singh too meet me on October,
31, 1984 was made because I apprehended that this event could trigger some
sort of blacklash against the members of my community, I was apprehensive
because of the events which had preceded the assassination of Ms.Indira
Gandhi including Operation Blue Star.

In Paragraph 3
of my affidavit I have mentioned that the gentle men referred to in the
paragraph returned to my house within 15 minutes. This was because they
apprehended danger on account of the acts of violence that had already
started taking place on the streets against the Sikhs. They had also been
warned by some well-meaning non-Sikhs and advised not to proceed further on
account of acts of violence against the Sikhs. Yet another reason which
prompted them to return back was to discuss our further course of action in
view of this violence. So we rang up Rashtrapati Bhavan and arranged to
meet the President at 12.15 the next day, i.e. on November 1, 1984.

We met the
President as he was the Country’s constitutional had and had long experience
in matters of governance. We expected him to take prompt action to prevent
further carnage and violence. It was wit that hope that we not only me him
but also suggested that he speak to the new Prime Minister.

On return from
the meeting with the President of India, there was a telephone message from
Mr.Inder Kumar Gujral and on his suggestion General Aurora, he and I went to
meet the Home Minister, Mr.P.V.Narasimha Rao at 3 P.M. on the same day, i.e.
November 1. The meeting with the Home Minister lasted for more than an
hour. When we arrived at the Home Minister’s House there was only his
Principal Private Secretary present in the living room. Thereafter the Home
Minister came out of his bedroom. There were no activity in the house.
There was nothing in the house suggestive of any meetings taking place with
officials etc. We did not notice any hustle or bustle or a sense of crisis
which could suggest that he was concerned with what was happening in Delhi,
or, to indicate that he had initiated action to curb violence in the
country’s capital. During our discussion with him we found him totally
unresponsive to the crisis.

We suggested
various steps which could be taken for avoiding large-scale violence. We
also suggested that the army should be called in to control the situation
immediately.

His reply was
that he was well informed about the happenings in Delhi and the army would
be deployed by that evening. In fact the army was not called till the
evening of November 3. While we were talking to him he did not receive any
telephone call, nor made any calls. No officer came to see him during this
period either.

Cross Examination by Shri K.K.Sud, Addl. Soliciter
General

On SA

I had not filed
any affidavit earlier before any commission or authority. I did not make
any representation or any written complaint to any authority including the
President and the Prime Minister as I had lost faith in them. I am aware of
the appointment of Justice Ranganath Mishra Commission and the Committees
appointed by the Commission. I know that Mr.Gujaral, Mr.Aurora, Air Marsahal
Aurjan Singh and Ambassodor Gurbachan Singh were all pursuing the demand
for bringing persons to the book for the massacre for the members of the
sikh community. I had again had a meeting with the President of India and
had suggested to him to take appropriate action against the guilty persons
but no steps were taken and therefore I was disenchanted and therefore did
not pursue my efforts further. I wrote several articles expressing my
anguish about the inaction of the authorities in taking action. I can
produce the articles written by me in that behalf.

I have also
mentioned about the inaction in the Government and the authorities in some
of the books which I have written. We had given the number of my car and
theefore we had entered the estate of the President straighway. We were not
frisked. I do not know whether any record will be maintained in the
President Office as regards our visit. What I had stated in my affidavit
regarding breaking out of the violence is based upon what I was told by the
gentleman referred to Para 3 of my affidavit who had come to my house
after leaving returned within 15 min. because of the violence.

I will produce
the copies of the articles and the book within about a weeks time.

Cross Examination by Shri
S.S. Gandhi, Sr. Advocate

The gentleman
had seen two taxis being burnt on Lodhi Road and there two sikh drivers also
told them that the mobs were moving around and they had damaged that taxis.
They were also informed at about that time by persons traveling in a car
that the Sikhs are being targeted and therefore should not proceed further.
The persons who had so informed were non-sikhs.

When those
gentleman returned to my house they informed me about the mobs being
damaging the property of the Sikhs but not about any killing of any Sikh
gentleman. I cannot say if any offence was registered as FIR No.242 dated
31.10.84 by the Tughlak Road Police Station with regard to the burning of
the vehicles which was witnesses by the gentleman.

When I was going
to the President Hosue on 1.11.84 a mob had tried to stop my car near PM’s
Office but we were able to get through as we did not stop the car. I had
seen Delhi Police men deployed on the road. On November 2, 1984 the
property belonging to me and my sister situated on Gurgaon-Sona Road were
burnt to the ground and an offence was registered.

Mr. Patwant
Singh, has forwarded alongwith his letter dated 26th April, 2001
four cuttings from newspapers and three books as promised by him while
giving his evidence.